Privacy Policy

Introduction

GamFam is a registered charity set up by those who have experienced first-hand the devastating effects that gambling can have. GamFam provides a strong support network for both gamblers, those in recovery and those affected by someone else’s gambling. Through GRA5P, our structured self-help peer support programme, we hope to offer guidance and practical suggestions on how families and friends can help themselves, which in turn will help the gambler.

This Privacy Policy (“Policy”) explains how we use your personal data when you use our website, take part in GRA5P or participate in a campaign we run.

It does not address other types of data processing we may undertake including in relation to HR, employment or where we provide services on the basis of a contract. Additional policies are in place addressing these processes and are provided to relevant data subjects as required by law.

 

Data Controller

The Data Controller of personal data processed in accordance with this Policy is GamFam, registered in the UK with company number 12255967 and address 19 Holywells Road, Ipswich, IP3 0DL, UK.

If you have any questions about this Policy, how we deal with your personal data, or to exercise your rights as a data subject, you can contact us via post to our registered address or email to info@gamfam.org.uk

 

Guiding principles

GamFam makes efforts to ensure it processes personal data lawfully, transparently and with adequate protections in place. We limit personal data processing to what is necessary for the purpose it was collected for. We also run GRA5P groups on an “anonymous” basis – meaning first names only are shared and participants are required to respect each other’s privacy and confidentiality.

 

What personal data do we process and why

 

GRA5P

GamFam offers support to individuals affected by gambling through GRA5P – our Recovery and Support Programme, which is a structured, 5-stage self-help programme designed specifically to support gamblers, those in recovery and those affected by someone else’s gambling. It offers guidance, support, and practical suggestions for coping day-by-day and moving towards a more positive future.

In general, the personal data collected when you participate in GRA5P is limited to your first name, email address, phone number and the details of your situation that you choose to share with us. This data is processed on the basis of your consent.

 

Initial contact

When you make contact with us about joining GRA5P either through the contact form on our website, via email or through our social media pages, we collect your first name, email address and phone number, along with some details of your situation. We use this information to log your request and organise an initial screening call with one of our Facilitators. After this call, if we believe GRA5P can offer you support, you will be invited to join a GRA5P group.

 

Group meetings

Participants will join group meetings chaired by a trained Facilitator. These are currently being held online using Zoom and participants can share audio, video and their first names. Participants may choose what other information they share at a meeting and limit this to what they feel comfortable with. All participation is on a first name basis only.

 

Notes

The Facilitator will create a group overview sheet and take minutes of each meeting, recording brief details of what was shared by Participants and any action points. These notes are used to manage the group, keep track of what’s going on for participants and to provide support. Meeting notes are uploaded to a secure cloud storage space and accessible only to the GamFam team members who need to access these. Generally, this is limited to the Facilitator and their Manager for the purposes of managing the group, keeping track of progress and to record and manage any safeguarding issues that may arise.

 

WhatsApp groups

Facilitators also run closed WhatsApp groups for each GRA5P group, where participants can check in with one another and communicate about meeting attendance.

 

Safeguarding

If a participant discloses that they are at risk of harm or at risk of causing harm to others, we have a responsibility to record this in our meeting notes and direct you to relevant helpful services. In some cases, we may also be legally required to report this to relevant authorities. We also report the number and nature of safeguarding issues that arise to our trustees, but we do not share any personal data for this purpose. We process this data on the basis of legal obligations on us, to protect the vital interests of the individual and/or our legitimate interests in administrating our organisation.

 

Campaigns

To protect individuals from the harms that gambling may cause, we participate in and run campaigns to collect information from members of the public which we use to compile reports about how gambling directly affects gamblers, their families and friends. We submit these reports to government departments in order to encourage them to make changes to laws around gambling. We may invite members of the public to submit their names for signature on a petition, or submit details of their situation for compilation in a report. We ask individuals to provide a contact email address to verify their submissions and to choose how they are referred to (e.g. anonymously, by first name only or full name). We process this data on the basis of consent.

 

Mailing list

Occasionally we send emails with updates on and news about our work to our network, including individuals who have participated in GRA5P, have engaged with GamFam through a campaign or have consented to join our mailing list. We send these emails on the basis of our legitimate interests in connecting with our network or on the basis of consent. These emails can be unsubscribed from at any time, by replying with “unsubscribe”.

 

Events

GamFam presents talks and events at schools and other organisations. Typically, no personal data is processed for this purpose. All in-person events are currently postponed due to the pandemic.

 

Retention

Generally, personal data is retained only for as long as is necessary to carry out the purpose it was collected for. GRA5P participant data is retained for two years from when it was collected, including initial contact records and meeting notes. This is for the purpose of record keeping and to ensure that details are retained for an appropriate period if a participant leaves the course and later returns.  At the end of the applicable retention period and/or when the personal data is no longer required, it is securely and permanently deleted.

 

Sensitive data

Certain types of data are classed as “special category” under data protection laws including the GDPR. A higher threshold of data protection standards are in place in relation to this data as it concerns information deemed to be potentially sensitive. Special category data includes information about a person’s race, ethnicity, sexuality, health status and political or philosophical beliefs.

GamFam does not request or require that any special category data is disclosed, but individuals might choose to share this if relevant in an initial contact, group meeting or for a campaign. If you choose to provide this information, the legal basis for this processing is your consent.

 

Cookies

To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

 

Information security

We take steps to ensure that personal data is processed securely and treated in accordance with this Policy. The technical and organisational measures we put in place to prevent unauthorised access to personal data include limiting staff and contractor access to personal data in accordance with specific job responsibilities or contractual obligations, the encryption of data where possible and the institution of security protocols and staff training.

Although we do our best to protect personal data, information transmitted over the internet remains vulnerable to interception – for this reason, any personal data shared over the internet with us is at the data subjects’ own risk.

 

Data sharing and processors

GamFam engages certain third parties to process data on its behalf, this includes cloud computing providers. Data is shared with these third parties on the basis of agreements which ensure confidentiality and compliance with data protection laws.

Data may be shared with government departments for the purposes of Campaigns. Individuals can choose which data of theirs is shared and can remain anonymous, as set out above.

 

Your rights

Where GamFam processes your personal data, you may have the right:

• to be informed as to whether GamFam holds data about you.
• to access that data.
• to have inaccurate data corrected.
• to have your data deleted.
• to opt-out of particular data processing operations.
• to receive your data in a form that makes it “portable”.
• to object to data processing.
• to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.

You can seek to exercise these rights via email to info@gamfam.org.uk  or post to GamFam, 19 Holywells Road, Ipswich, IP3 0DL, UK. You also have the right to lodge concerns or complaints with the UK Information Commissioner’s Office.

 

Changes and revisions to policy

This Policy was published 10th July 2021.

This Policy may be updated from time to time. Material changes and revisions will be listed here and/or communicated to affected data subjects as required.